DCT
1:12-cv-00426
Power Management Solutions LLC v. Advanced Micro Devices Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Power Management Solutions LLC (Delaware)
- Defendant: Advanced Micro Devices, Inc. (Delaware)
- Plaintiff’s Counsel: Proctor Heyman, LLP; Morris, Manning & Martin, LLP
- Case Identification: 1:12-cv-00426, D. Del., 04/05/2012
- Venue Allegations: Venue is alleged to be proper in the District of Delaware based on Defendant's incorporation in the state of Delaware.
- Core Dispute: Plaintiff alleges that Defendant’s A-series processors infringe a patent related to on-chip power management systems that can selectively power down functional units on an integrated circuit.
- Technical Context: The technology concerns methods for reducing power consumption in complex integrated circuits, a critical design consideration for mobile and battery-powered devices.
- Key Procedural History: The complaint does not allege any prior litigation, licensing history, or other procedural events relevant to the asserted patent.
Case Timeline
| Date | Event |
|---|---|
| 1994-01-21 | '909 Patent Priority Date |
| 1996-04-02 | U.S. Patent No. 5,504,909 Issued |
| 2012-04-05 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
- Patent Identification: U.S. Patent No. 5,504,909, "Power Management Apparatus Collocated On The Same Integrated Circuit As The Functional Unit That It Manages," issued April 2, 1996.
- The Invention Explained:
- Problem Addressed: The patent describes challenges with prior art power management techniques that operated at the printed circuit board level. Such systems were complex, wasted energy by repeatedly charging and discharging board-level capacitors, and suffered from slow power-up times, limiting their utility for functions requiring rapid power cycling (’909 Patent, col. 2:16-41).
- The Patented Solution: The invention proposes moving the power management function directly onto the integrated circuit (IC) that it controls (’909 Patent, col. 2:52-62). It collocates a "power gating means" (to switch power) and a "switching means" (to isolate data signals) on the same IC substrate as the "internal functional circuit" being managed. As depicted in Figure 2, a single external control signal can be used to simultaneously remove power from the functional circuit via the power gate (60, 61) and isolate its input/output lines via the I/O switches (62, 63), effectively and rapidly powering it down to conserve energy (’909 Patent, Abstract; col. 7:1-10).
- Technical Importance: This on-chip approach allows for decentralized, granular power management of individual functional blocks within a single IC, enabling faster "submicrosecond recovery" and avoiding the power waste associated with board-level power plane cycling (’909 Patent, col. 19:15-22).
- Key Claims at a Glance:
- The complaint asserts independent Claim 1 (Compl. ¶11, 15).
- Essential elements of Claim 1 include:
- An integrated circuit substrate.
- An internal functional circuit, a power gating means, and a switching means constructed on the substrate.
- The power gating means controllably passes power from an external supply to the internal functional circuit.
- The switching means controllably passes electrical signals between an external functional circuit and the internal functional circuit.
- A single "second externally generated electrical signal" controls both the power gating means and the switching means.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
- Product Identification: The complaint identifies the "AMD A6-3400M Processor, Part No. AM3400DX43GX," referred to collectively as the "AMD Products" (Compl. ¶10).
- Functionality and Market Context: The complaint alleges that the AMD Products are integrated circuits that contain "one or more power management apparatus that couple and decouple internal and external electrical functional circuits" (Compl. ¶10). The complaint does not provide further technical detail on the operation of the accused power management features or the products' market position.
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
The complaint alleges infringement of at least Claim 1 of the ’909 Patent but does not map specific features of the accused products to the claim limitations beyond a general assertion (Compl. ¶11).
’909 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| an integrated circuit substrate whereon 1) the internal functional circuit, 2) a power gating means, and 3) a switching means are constructed... | The complaint alleges the AMD Products are integrated circuits containing power management apparatus (Compl. ¶10), but does not specifically identify the structures corresponding to the internal functional circuit, power gating means, or switching means. | ¶10, ¶11 | col. 19:25-29 |
| wherein electrical power is controllably passed from an external power supply through the power gating means to the internal functional circuit... | The complaint alleges the AMD Products contain apparatus to "couple and decouple" circuits but does not describe how power is controllably passed through a specific structure (Compl. ¶10). | ¶10, ¶11 | col. 19:29-32 |
| wherein one or more first electrical signals are controllably passed between an external functional circuit and the internal functional circuit via the switching means... | The complaint alleges the AMD Products contain apparatus to "couple and decouple" circuits but does not describe how signals are controllably passed via a specific structure (Compl. ¶10). | ¶10, ¶11 | col. 19:32-36 |
| and wherein a second externally generated electrical signal controls the coupling action in the power gating means via a first control input of the power gating means and further controls the coupling action in the switching means via a second control input of the switching means... | The complaint does not identify an "externally generated electrical signal" in the AMD Products or allege facts showing how such a signal controls both a power gating structure and a signal switching structure. | ¶11 | col. 19:36-42 |
| the power gating means for coupling power...in response to the assertion of said second externally generated electrical signal... | The complaint does not provide sufficient detail for analysis of this element. | ¶11 | col. 19:44-col. 20:2 |
| the switching means for coupling said first electrical signals...in response to the assertion of said second externally generated electrical signal... | The complaint does not provide sufficient detail for analysis of this element. | ¶11 | col. 20:5-13 |
- Identified Points of Contention:
- Scope Questions: Claim 1 recites "power gating means" and "switching means." These terms may be construed under 35 U.S.C. § 112(f) as means-plus-function limitations. A central dispute will be whether the scope of these terms, which is limited to the corresponding structures disclosed in the patent specification and their equivalents, reads on the specific power management and signal isolation circuitry within the accused AMD processors.
- Technical Questions: A key evidentiary question will be whether Plaintiff can demonstrate that the accused AMD processors employ a structure that performs the identical function recited in the claims. For example, the complaint does not provide evidence that a single external signal in the accused processors simultaneously controls both the power delivery and signal path isolation for a given functional block, as required by Claim 1.
V. Key Claim Terms for Construction
The complaint’s sparse allegations suggest that the construction of the means-plus-function terms will be dispositive.
The Term: "power gating means"
- Context and Importance: This term defines the core component for switching power to the functional circuit. Its construction will determine what specific type of on-chip structure can meet this limitation. Practitioners may focus on this term because its scope under § 112(f) is tied directly to the structures described in the patent's specification.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim itself recites the function broadly as a means "for coupling power between said external power supply and the internal functional circuit" and "for uncoupling power" (’909 Patent, col. 19:44-col. 20:2).
- Evidence for a Narrower Interpretation: The specification defines a "power gate" as "a power switching means used herein for making or breaking a connection between a power source and its load on command, implemented as an electrically controllable electronic switch" (’909 Patent, col. 4:60-63). An argument could be made that the corresponding structure is limited to this specific implementation and its equivalents.
The Term: "switching means"
- Context and Importance: This term defines the component for isolating the functional circuit's data signals. Its construction is critical to determining whether the accused products' I/O circuitry infringes, particularly in coordination with the "power gating means".
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The claim describes the function as a means "for coupling said first electrical signals" and "for uncoupling said first electrical signals" in response to the control signal (’909 Patent, col. 20:5-13).
- Evidence for a Narrower Interpretation: The specification defines an "I/O switch" (the structure corresponding to the claimed means) as an "electronically controllable electronic signal switching means used herein for isolating a powered-on circuit from a powered-off circuit" (’909 Patent, col. 4:11-14). This suggests a specific purpose of isolation that may narrow the term's scope.
VI. Other Allegations
- Willful Infringement: The complaint seeks a finding of willful infringement in its prayer for relief (Compl., Prayer ¶1). However, it does not plead any specific facts indicating that Defendant had pre-suit knowledge of the ’909 Patent. The basis for willfulness appears to rest on the notice provided by the filing of the lawsuit itself, which would only support a claim for post-filing willfulness.
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of claim construction under § 112(f): How will the court construe the functions of the "power gating means" and "switching means" limitations, and crucially, what specific structures disclosed in the ’909 Patent specification will define the scope of those terms? The outcome of this legal determination will dictate the infringement analysis.
- The dispositive evidentiary question will be one of structural correspondence: Can the Plaintiff, through discovery and expert testimony, identify specific circuitry within the AMD A6-3400M processor that constitutes a "corresponding structure" to the means-plus-function limitations of Claim 1? The complaint’s conclusory allegations leave this as an entirely open question.